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Code of Conduct

Making good on our promises

Message from Chairman and CEO

Dear Colleague:

Aetna’s reputation as an industry leader depends on our ability to deliver on our promises. For more than 160 years, we have been guided by the highest standards of integrity. Our relationships with our customers, business partners and suppliers are built on trust earned over time and through experience. Each day we must remember our commitment to do the right thing for the right reason and keep the people we serve at the center of everything we do. When we act with integrity, we are living The Aetna Way.

Our Code of Conduct is grounded in and reflects the principles at the heart of The Aetna Way. The Code guides our compliance with the rules and regulations that govern our business throughout the world. Compliance with our Code and other regulatory requirements is everyone’s responsibility, from the top to the bottom of our organization. We not only expect this commitment of our associates, but we also expect our contractors and subcontractors, including but not limited to Medicare first tier, downstream and related entities, to maintain comparable policies and practices.

If we apply this Code to all aspects of our business, we will fulfill our promise to operate in accordance with the law, company policies and our core values.

Although the Code can’t cover every imaginable situation, it does provide you with examples of everyday situations to assist you in resolving potential problems and general guidance for performing your job responsibilities with integrity and in concert with our culture and beliefs. Also included is a list of contacts for you to use in seeking advice or reporting concerns.

Ultimately, our reputation depends on the sound judgment and personal character of every Aetna associate, regardless of your level in the organization. But, we do hold our leaders to an even higher standard, as they are expected to embody our core principles every day in all that they do. By modeling consistent honest, ethical behaviors to associates, they are at the helm of promoting, upholding and strengthening Aetna’s culture of integrity.

If you are ever in doubt as to the right course of action, use The Aetna Way and our Ethical Decision-Making Framework to help you make the right decisions. If you ever have reason to believe that a legal or ethical violation has occurred, you need to report it immediately. Your leader is the first person you should consider speaking with. But there are other resources available, including Human Resources, Compliance, the Law Department, Corporate Security, Investigative Services or the confidential Aetna AlertLine®. Our policies forbid any form of intimidation or retaliation against you for fulfilling this obligation.

I expect each of you to read, understand and follow our Code of Conduct. Please consult it throughout the year, as needed. Your commitment to compliance, all company policies, and the laws and regulations applicable to our businesses contributes directly to our success as a company. Please join me in living our commitment to protecting and strengthening Aetna’s reputation for integrity and keeping our promises to each other and those we serve.

We have served our customers for more than 160 years, consistently guided by the highest standards of integrity.

Mark T. Bertolini


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